How the DGT's position has evolved
Current position
The right to pass on VAT (IVA) is lost if one year has elapsed from the accrual date, unless the recipient voluntarily agrees to bear the late pass-on. For the pass-on to be valid, the invoice must be issued and delivered to the recipient within said period. In cases of modifications to the tax base due to subsequent discounts, the rectification must comply with the four-year statute of limitations.
The DGT's position remains constant regarding the one-year period for the pass-on of VAT (IVA) and the requirement to deliver the invoice. Recent rulings do not change this principle, but rather apply it to specific scenarios such as packaging or rectifications due to discounts. No doctrinal change is observed, but rather a repeated application of the same criterion.
Analysis based on 62 of 65 rulings with a stated position. Updated 21 September 2026.